Opinion — Let facts dictate actions on Coakley PFAS cleanup

“Issues surrounding the Coakley landfill are complicated and contentious, with concerns ranging from a potential Seacoast cancer cluster to detection of perfluorinated compounds in community wells.

As a result, the Coakley Landfill Group, its record keeping, past decisions and its management of ongoing site remediation, has come under intense scrutiny…

[Even] as questions linger, the CLG and our community should still be planning for the future, even if doing so is complicated by the landfill being a Superfund site.

A consent decree between the Environmental Protection Agency and the major parties that contributed waste to the landfill (now CLG members) holds CLG liable for the cost and performance of cleanup at the Coakley landfill.

According to the EPA, the state cannot require stricter remediation standards without the EPA’s approval.

However, recent remarks by the EPA and City Attorney Robert Sullivan (chair of the CLG executive committee) seem to indicate that if the CLG members sought approval of a more stringent remediation process than is required, it would likely be granted.

That caused me to question why the EPA removed the one-time requirement of constructing a groundwater pump-and-treat remediation system at the landfill, but the EPA explained its reasoning in a 1999 Explanation of Significant Differences (ESD). And the New Hampshire Department of Environmental Services concurred.

‘EPA permitted delay of the groundwater collection and treatment system construction to allow an evaluation of the impacts of the landfill cap on the groundwater,’ DES said. ‘The results of this evaluation indicate that elimination of the groundwater extraction and treatment component…could achieve significant cost savings while remaining protective of public health and the environment.’

DES found the EPA’s remedy was in accordance with state standards. It is also unlikely that such a system, even if installed at that time, would have addressed the now emerging concerns surrounding PFCs. The EPA has not permanently ruled out a more aggressive cleanup plan, but it has found the current system to be ‘protective in the short-term’ with ‘no human exposures above cleanup standards.’

To ensure long-term protection, the EPA has suggested several next steps, like a deep bedrock investigation, further evaluating risks from exposure to PFCs (like PFAS and PFOA) and conducting fish-tissue sampling along Berry’s Brook…

The science concerning the consequences of exposure to PFCs is still evolving. The Agency for Toxic Substances and Disease Registry has stated that although the health effects from PFCs are not yet clear, they could be linked to cancer, developmental delays and more. But state and federal regulators have said they cannot prove or disprove whether contaminants from the Coakley landfill are causing cancer.

Attorney Sullivan has said the CLG’s authority is limited, and funds dedicated to remediation are kept in a trust account at a bank that manages payment of CLG approved expenses. The CLG has also recorded its monthly activities since 1992, but those records had been hard to come by until recently; 145 boxes of materials have now been collected and made available. Given the volume of information, even attorney Sullivan agrees it would have been better if the CLG had conducted annual summaries over the years.

Like you, I want to be certain taxpayer money has been managed well, that remediation is effective and long-term health effects of contaminants are thoroughly understood and avoidable.

While decades of CLG records are searched, a city financial review takes place and scientific data is collected, the CLG, city leaders and our community should also be looking for ways to improve the situation.

The CLG should work with the EPA to address emerging contaminants and health concerns, explore additional forms of remediation and take prompt action once new studies are complete, like the bedrock study beginning this summer.

It may also be worthwhile for the CLG, or some of its members, to pursue state and federal funds that can be used to extend water lines to communities in need of cleaner, safer water.”